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Germany โ€“ Israel Tax Treaty

The Germany-Israel tax treaty caps withholding on dividends at 15% for portfolio investors and 5% for qualifying direct investment, and interest at 5%. Royalties are taxed at a uniform 5% across all categories. Private pensions are taxable only in the country of residence, with no withholding at source. This is one of 49 active treaties in Germany's network and one of 24 in Israel's. The general dividend rate of 15% compares to a median of 15% across Germany's network and 15% across Israel's.

Verified data

BMF DBA Collection (bundesfinanzministerium.de) (Treaty list verified April 2026. Rates from individual treaty texts (Articles 10-12).)

Withholding Rate Summary

Source: Germany Treaty Reference
Income TypeTreaty RateStatutory Rate (Germany)
Dividends (general)

Portfolio investors

15%saves 11%26%
Dividends (qualified)

Beneficial owner is a company holding >= 10% of voting stock

5%saves 21%26%
Interest

Bank interest, bonds, loans

5%0%
Royalties (avg)

Patents, copyright, know-how, film/TV

5%โ€”
Pensions

Private pension distributions

0%โ€”
Social Security

Government social security benefits

0%โ€”

โ€œTreaty Rateโ€ is the maximum withholding permitted under this treaty. The actual effective rate may be lower if domestic law provides a more favorable rate independently. โ€œStatutory Rate (Germany)โ€ shows the rate that applies when no treaty benefit is claimed. Qualified dividend rate requires: Beneficial owner is a company holding >= 10% of voting stock.

Dividends
General Rate15%saves 11% vs statutory
Qualified Rate5%saves 21% vs statutory
Statutory Rate26%without treaty

The general dividend rate of 15% applies to portfolio investors. A reduced rate of 5% is available when beneficial owner is a company holding >= 10% of voting stock. Without the treaty, the statutory withholding rate on dividends is 26%.

Source: Germany Treaty Reference

Interest
Treaty Rate5%treaty rate
Statutory Rate0%without treaty

Interest payments (bank interest, bonds, loans) are subject to 5% withholding under this treaty, compared to the 0% statutory rate. This represents a no reduction from the statutory rate.

Source: Germany Treaty Reference

Royalties
Know-how5%
Patents5%
Film & TV5%
Copyright5%

Royalty withholding rates vary by the type of intellectual property. This treaty distinguishes 4 categories, with rates ranging from 5% to 5%.

Source: Germany Treaty Reference

Pensions & Social Security
Pensions0%exempt at source
Social Security0%exempt at source

Private pension distributions are taxable only in the country of residence, with no withholding at source. Government social security benefits are exempt from source-country withholding.

Source: Germany Treaty Reference

Comparative Context

๐Ÿ‡ฉ๐Ÿ‡ชGermany's Network

Among Germany's 49 active treaty partners, the 15% general dividend rate ranks 26th (median: 15%).

PartnerRate
Hungary15%
Indonesia15%
Ireland15%
Israel (this treaty)15%
India15%
Italy15%
Japan15%

๐Ÿ‡ฎ๐Ÿ‡ฑIsrael's Network

Among Israel's 24 active treaty partners, the 15% general dividend rate ranks 10th (median: 15%).

PartnerRate
Canada15%
Switzerland15%
Czech Republic15%
Germany (this treaty)15%
France15%
United Kingdom15%
Greece15%

Frequently Asked Questions

What is the dividend withholding rate under the Germany-Israel tax treaty?
The general dividend withholding rate is 15%. A reduced rate of 5% applies when beneficial owner is a company holding >= 10% of voting stock. Without the treaty, the statutory rate is 26%. Source: Germany Treaty Reference.
What is the interest withholding rate between Germany and Israel?
The treaty rate on interest is 5%, compared to the 0% statutory rate. Source: Germany Treaty Reference.
How are pensions taxed under the Germany-Israel treaty?
The treaty withholding rate on pensions is 0%. Source: Germany Treaty Reference.

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